When a chemical is transferred from its original container to another, the second storage device is referred to as a “secondary container” or “workplace container.” Given the common practice of transferring chemicals from one container to another, OSHA has included requirements for proper secondary container labeling as part of the Hazard Communication Standard (HCS) to ensure workers are aware of the chemicals they are exposed to.
The most recent revision of HCS aligns U.S. hazardous chemical labeling standards with those of the international GHS (Globally Harmonized System of Labeling and Classifications), making it easier for everyone to understand the hazards related to chemicals nationally and internationally. Though hazardous chemical label requirements dictated by GHS have been made very clear, many are still confused as to how and if requirements for secondary container labels have changed, and if so, what those requirements are.
Secondary Container Label Requirements
Employers must make sure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with either of the following:
All the information specified for the labels on shipped containers.
The product identifier and words, pictures, symbols, or a combination that provide at least general information about the hazards of the chemicals.
Generally, things that must be labeled include:
- Storage bottles created for the distribution of small amounts of a material.
- Storage bottles for solutions or dilutions of a chemical.
- Sample vials or sealable tubes. Large batches of the same compound may be labeled collectively, provided that they are stored and handled as a group.
Only a few exceptions apply to secondary container labels. These include:
If the container size is impractical to house a label.
If the chemicals are produced in a workplace but are not intended for sale.
Products meant for immediate use. Immediate use means the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and will be used only during the work shift in which it is transferred.
In all the above cases, management is responsible for creating an alternative system that provides the same information provided on the original GHS-compliant label in a different written or displayed format. For example, a process sheet, placard, or other written material that includes the details can be displayed in the workplace.
Container labeling not only provides important safety information but also gives companies the ability to accurately track all the hazardous products and chemicals they have. This becomes valuable not only for regulatory compliance purposes, but it is also advantageous for companies interested in tracking chemical life cycles. A barcode or a specific classification number on the label creates an understanding of how a material enters a facility, how it is used, and how it leaves as waste. Finally giving companies visibility into their hazardous material handling processes from beginning to end.
Because secondary container labeling rules are essential to the safety of the workforce, enforcement institutions take them very seriously. So be sure to educate all employees and supervisors on good practices.